Updated on 07/26/2022
Table of contents:
- Persons Under the Age of 16
- Special Notification for California Residents — Your California Privacy Rights
- Information We Collect and Receive About You
- Automatic Data Collection
- How We Use Your Information
- How We Disclose Your Information
- Making Choices About Your Information
- Data Security
- Information for European Residents
- GDPR Data Protection Rights
- Contact Information
Cubesnack, Inc. (“Cubesnack” or “we”) respects your privacy and protects your personal information as set forth in this policy.
This policy describes the type of information we may collect from you or that you may provide when you visit the website www.cubesnack.com (our “Site”) or mobile app Cubesnack, and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to the information we collect:
- On our Site or Mobile App;
- Directly from you through your use of our Site or Mobile App;
- In email or other electronic messages between you and our Site or Mobile App;
- On behalf of or through third parties.
2. Persons Under the Age of 16
Our Site is not intended for persons under 16 years of age. No one under age 16 may provide any information to or on our Site. We do not knowingly collect personal information from persons under 16. If you are under 16, do not use or provide any information on our Site or on or through any of its features, use any of the interactive features of our Site or provide any information about yourself to the Company, including your name, address, telephone number, email address, or any other information. If we learn we have collected or received personal information from a person under 16, we will delete that information. Furthermore, if you believe we might have any information from or about a child under 16 years of age, please contact us at email@example.com.
3. Special Notification for California Residents — Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around Cubesnack’s collection, use, and sharing of their personal information. California law permits users of our Site that are California residents to request certain information regarding our collection and disclosure of personal information. To make such a request, please send an email to firstname.lastname@example.org or call 1(877)726-1990. California residents may also opt out of the sale of their personal information by following steps described on the Do Not Sell My Personal Information web page.
We collect various categories of personal information when you use our Site, including identifiers, commercial information, Internet or other electronic network or device activity information, and geolocation data. A more detailed description of the information we collect and how we use it is provided below in the sections “Information We Collect and Receive About You” and “How We Use Your Information.” Furthermore, the section “How We Disclose Your Information” describes the categories of third parties with whom we may share personal information, and what information may be shared under different circumstances. California Do Not Track Disclosure: Note that we do not respond to browser do-not-track (DNT) signals.
If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access such information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow Cubesnack to retain and use certain personal information notwithstanding your deletion request. You may send your request for access to that information or deletion by email to email@example.com or call 1(877)726-1990. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.
Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. Such requests must be submitted to us at firstname.lastname@example.org, through the toll-free number 1(877)726-1990, or in writing at:
Cubesnack, Inc., 3 Audrey Avenue, Oyster Bay, NY 11771, Attn: Legal Department.
California privacy rights requests must include the reference “Request for California Privacy Information” in the subject line, and in the body of the message, and must include an email address or mailing address that we may use for the response. We reserve the right not to respond to requests submitted other than as specified above.
4. Information We Collect and Receive About You
We may receive or collect several types of information about you (“Your Information”), such as the information described below, information you provide to us, as well as information we collect through automatic data collection technologies as described below (e.g., usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies).
Examples of Your Information include:
information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline; information about you but by itself does not identify you individually, such as zip code; or information about your Internet connection, the equipment you use to access our Site, your Internet protocol (IP) address, your location (e.g., mobile device’s GPS coordinates, location of nearby Wi-Fi), your browser type, your device type and operating system, and usage details and search queries.
You may provide Your Information to us:
- When you fill out forms or fields through our Site;
- When you sign up for any newsletters or other materials, or other products and services through our Site;
- When you provide information to us through a third-party application, service, or website (including social media websites (i.e., Facebook, Instagram, LinkedIn, Twitter, or others));
- When you communicate with us or request information about us or our Site, whether by email, telephone, or otherwise.
5. Automatic Data Collection
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment and browsing actions, including details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact us at email@example.com if you would like to opt out of behavioral tracking on this Site and learn how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. California Do Not Track Disclosure: Otherwise, please note that we do not respond to browser do-not-track (DNT) signals.
The information we collect automatically includes statistical data and helps us improve the Site and deliver a more personalized service to you. It also enables us to (a) estimate the number of users of our Site and usage patterns; (b) store information about user’s preferences so that the Site can be customized for users; (c) recognize users when they return to the Site; and/or (d) present search results more quickly.
Various technologies used for such automatic data collection may include:
Flash Cookies: Certain features of our Site may use local storage objects or Flash cookies to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. Third parties with whom we partner to provide certain features on the Site or display certain advertising use Flash cookies such as HTML5 Storage to collect and store information.
Web Beacons: Our Site may contain small electronic files known as web beacons (pixel tags) that allow us or our partners to count users who have visited certain pages, gauge the popularity of certain content, track the opening of certain emails, track users’ movements around the Site, gather demographic information about users, or collect related statistics.
Log Files: This Site gathers certain information automatically and stores it in log files, including information such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), operating system, date/time stamps, and web pages visited or accessed. We may combine this automatically collected information with other information we collect about you. It enables us to (a) improve services we offer you; (b) improve marketing, analytics, or site functionality; and (c) keep track of your consent to receiving services or communications from us or third parties. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we treat all such information as personally identifiable information.
Network Advertising: We may participate in, partner with, or use advertising networks, such as third-party advertising servers, technology vendors, and research firms. For example, we use Google AdSense to publish ads on our Site. When you view or click on an ad, a cookie will be placed (as described above) so that we can show you advertisements that may be of interest to you on the Site or other sites. We may also use third-party advertising networks to present ads to you on our Site, or to manage our advertising on other sites. As described above, our third-party partners may use technologies such as cookies to gather information about your use and navigation of this Site and other sites in order to provide you advertising based on your browsing history and interests. This practice is often referred to as “online behavioral advertising.” Please see the “Online Behavioral Advertising” subsection of “Making Choices About Your Information” below to read about how you can prevent certain third-party advertising networks from collecting information about you.
6. How We Use Your InformationIn addition to the uses described above, we may also use Your Information for other business purposes such as customer service support, market research, scientific research, sales information, payment processing, age verification, analysis of user behavior, maintenance and operation of the Site, improving and personalizing the Site, understanding how you use the Site, and developing new products, services, features, and functionality. For example, we may use Your Information to confirm and complete transactions requested by you, verify information you provide to us, provide you with administrative notices, provide you with information, products, or services that you request from us, notify you about changes to our Site or any services we offer or provide though it, and contact you by telephone, email, mail, or other communications with Site updates, promotional materials, surveys, offers, personalized information, and other information. We may also use Your Information to comply with this policy, monitor compliance with and enforce this policy, fulfill other legal and regulatory requirements, find and prevent fraud, and protect the security and integrity of our Site and Your Information.
7. How We Disclose Your InformationWe share Your Information with third parties as described in this policy. If you do not want Your Information shared as described in this policy, then you should not provide us with Your Information or use this Site. We may disclose Your Information:
- To our employees, contractors, service providers, partners and affiliates;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent (for example, your attorney);
- To third-party vendors who may provide support for our internal and business operations, including for the handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, payment processing, and Site maintenance and security;
- To third parties (which have their own privacy and use policies) when you engage in certain activities through our Site that are sponsored by them, such as social media services offered by a third party;
- As required by law or ordered by a court, regulatory, or administrative agency;
- As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, or regulation, or are otherwise interfering with another’s rights or property;
- To enforce or apply this policy, and any other applicable agreements and policies;
- To enforce or protect our rights;
- To a buyer or successor in the event of a merger, acquisition, restructuring, reorganization, or other sale or transfer of some or all of the Company’s assets;
In the aggregate: We may disclose aggregated information about our users without restriction. We may take Your Information and de-identify it by combining it with information about other individuals (aggregating Your Information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-identifying). We reserve the right to share, loan, rent, sell, or otherwise disclose such information to third parties at any time, for any lawful purpose, without notice or compensation to you.
8. Making Choices About Your InformationYou can review, access, correct, or delete your personal information that you have provided to us as described in this policy by sending us a request at firstname.lastname@example.org. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Online Behavioral Advertising: If you do not want third-party advertisers to collect your information for the purpose of sending you interest-based ads, you may opt-out by clicking here. Also, certain third-party advertisers that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You may prevent NAI member companies from collecting preference data about you by following the NAI directions here. You may opt-out of Google Adsense’s use of its cookie by visiting Google’s Advertising and Privacy page. Note that these opt-out options do not prevent all ads. You will continue to receive generic ads.
9. Data SecurityWhile we try to prevent accidental loss and unauthorized access, use, alteration, and disclosure of Your Information with certain physical, electronic, and managerial procedures, no method of transmission or electronic storage is 100% secure, and we cannot guarantee full security. In certain areas of our Site, we use industry-standard SSL-encryption to enhance the security of data transmissions. Take precautions to protect Your Information when using the Internet (e.g., change passwords periodically, keep passwords confidential, use strong passwords with combinations of letters and numbers, use a secure browser, be careful about giving out information in public areas of our Site like message boards). Additionally, we may have to disclose Your Information to government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. You therefore use our Site at your own risk and we do not promise or guarantee, and you should not expect, that Your Information will always remain private. In the event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by such third party’s ability to view, use, or disclose Your Information.
11. GDPR Data Protection Rights
Persons whose personal data is governed by the GDPR and other laws have rights related to the processing of their data, as explained below. The following are available to such persons:
The right to access personal data (GDPR Article 15). You have the right to obtain confirmation from us regarding whether we process personal data about you, and, if applicable, access to the personal data and certain information about how and why we process your personal data, including:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom the we share personal information; and
- The specific pieces of personal information we have collected about that you.The right to rectification of personal data (GDPR Article 16). You have the right to rectification and/or completion if your personal data is incorrect or incomplete.
The right to be erasure (right to be forgotten) (GDPR Article 17). You have the right to obtain the erasure of your personal data where one of the following grounds applies:
- Your personal data is no longer necessary in relation to the purpose for which it was collected or otherwise processed;
- You withdraw your previously given consent and we have no other legal ground for the processing;
- Your personal data has been unlawfully processed;
- Your personal data must be erased for compliance with a legal obligation; or
- Based on your request for any reason or no reason.
The right to restrict processing of personal data (GDPR Article 18). You have the right to restrict processing of your data under the following conditions:
- The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
- Your personal data has been unlawfully processed and you request the restriction of processing instead of deletion;
- We no longer need the personal data for the purpose of the processing, but the personal data is required by you for the establishment, exercise, or defense of legal claims; or
- You have objected to processing pursuant to GDPR Article 21, Section 1 and it has not been determined whether our legitimate grounds override yours.
The right to object to processing of personal data (GDPR Article 21). You have the right to object to our processing of your personal data based on legitimate interests (GDPR Article 6, Section 1(f)), for the performance of a task carried out in the public interest (GDPR Article 6, Section 1(e)) or for direct marketing purposes.
The right to data portability (GDPR Article 20). You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly-used, and machine-readable format. You also have the right to transmit those data to another controller without hindrance from us if:
- The processing is based on consent or on a contract pursuant to GDPR Article 6, Section 1(b); or
- The processing is carried out by automated means.
The right to lodge a complaint with a supervisory authority (GDPR Article 77). You have the right to lodge a complaint with the supervisory authority in the Member State of your habitual residence, place of work, or place of the alleged infringement.
Our legal bases under the GDPR for processing Your Information as discussed in this policy include:
the processing is necessary for the performance of a contract to provide you with our goods or services (GDPR Article 6, Section 1(b)); or
the processing is necessary for legitimate interests we pursue in operating our business and providing products and services to you (GDPR Article 6, Section 1(f)).
Our legal bases under the GDPR for processing cookie data (discussed above) include:
for processing necessary to carry out electronic communications with you or to provide certain functions desired by you; or if processing is pursuant to our legitimate interest in providing the technically error-free and optimized delivery of our services, we may process the data in accordance with GDPR Article 6, Section 1(f); or
for processing data related to cookies used for other purposes we may process the data in accordance with your consent (GDPR Article 6, Section 1(a)).
Log Files: Our Site, like most websites, gathers certain information automatically and stores it in log files, including information such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), operating system, date/time stamps, and web pages visited or accessed. We may combine this automatically collected information with other information we collect about you. It enables us to improve marketing, analytics, or site functionality or security. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we treat all such information as personally identifiable information under this policy.
Our legal basis under the GDPR for processing log file data includes:
Our legitimate interest in providing the technically error-free and optimized delivery of our services in accordance with GDPR Article 6, Section 1(f).
Web Beacons: Our Site’s pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us to count users who have visited certain pages, gauge the popularity of certain Site content, track users’ movements around the Site, gather demographic information about users, or collect related statistics.
Our legal bases under the GDPR for processing web beacon data include:
our legitimate interest in providing the technically error-free and optimized delivery of our services in accordance with GDPR Article 6, Section 1(f).
for processing necessary to carry out electronic communications with you or to provide certain functions desired by you; or if processing is pursuant to our legitimate interest in providing the technically error-free and optimized delivery of our services, we may process the data in accordance with GDPR Article 6, Section 1(f).
When we make changes to this policy, the date of such changes will be posted at the top of the policy so that you are aware changes have been made. Such changes to this policy may be material as to how we treat your personal information. You are responsible for periodically checking this policy for any changes.